In Matzat v. Matzat, the Indiana Court of Appeals addressed a highly contested issue: when can a spouse receive incapacity-based spousal maintenance, and what evidentiary showing is required? The decision is still widely cited because it draws a clear line between permissible judicial discretion and the necessity of objective proof. For attorneys handling maintenance claims, either requesting or opposing them, Matzat is essential reading.
Background of the case
The Matzats divorced after a long marriage. During the marriage, the wife worked as a licensed practical nurse, but over time, she developed medical problems that she claimed prevented her from continuing in that field. She testified that she also could not pursue data-entry work because of physical limitations, and that without support, she lacked the ability to maintain financial independence.
Relying heavily on the wife’s testimony, the trial court awarded her incapacity maintenance of:
- $200 per week, and
- An order that the husband pay the cost of her COBRA health insurance coverage until she began receiving Social Security disability benefits.
The husband appealed, arguing that the award was unsupported by the evidence and constituted an abuse of discretion.
Understanding the statutory framework for maintenance in Indiana
Under Indiana Code § 31-15-7-2(1), a court may award maintenance if the requesting spouse is physically or mentally incapacitated to the extent that the incapacity materially affects their ability to support themselves. The burden lies entirely on the requesting spouse, and the statute requires more than inconvenience or reduced earning power. It requires a demonstrable incapacity.
The appeal
The appellate court made it clear that while trial courts have a fair amount of discretion in these matters, it is not unlimited. When it comes to awarding maintenance, especially for incapacity, it has to be backed by more than just surface-level claims. And in this case, the only evidence the wife offered was her own testimony.
She neglected to provide medical records, did not call a doctor to testify, and there were no disability rulings or job evaluations to support her claim. In fact, there wasn’t much of anything that could objectively show she was unable to support herself. That lack of documentation really weakened her case.
According to the Court of Appeals, if a judge is going to award maintenance based on incapacity, there needs to be actual, competent evidence showing both that the incapacity exists and that it affects the person’s ability to work or be self-sufficient. Without that foundation, the court is basically guessing, and that’s not enough to meet the legal standard. The appellate court overturned the alimony award.
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